In 2012, parliament passed measures designed to substantially reduce criminal records checks, and particularly to reduce the burden on volunteers.
Yet six years later, this report finds that a particularly trusted cohort of volunteers – parent volunteers in schools – are being subjected to unprecedented levels of surveillance and control.
Parents are routinely being criminal records checked to help out in their child’s school, even for one-off events such as volunteering at the Christmas Fair or book sale.
The findings in this report include:
- There were 168,696 criminal records checks on school volunteers in the school year 2017-18, for activities including listening to reading, assisting on a school trip, or helping at the school disco. These include 8998 parents vetted for language exchanges, 2154 for helping on a school trip, and 8341 for listening to reading.
- Parents have been asked to undergo repeat criminal records checks for different school roles, and in some cases to pay the cost of their own checks.
This means that parent volunteers helping out on a school trip are subject to a higher level of security vetting than that required to own firearms or sell explosives.
In addition, parent volunteers have been subjected to formal procedures on a par with that required for teaching staff, including:
- Undergoing interviews and evaluations for volunteer positions; filling in long forms, including full professional history (including salary and grade of job), and providing references to attest that they are not a risk to children;
- Being asked to sign documents including whistleblowing policies, child protection policies, confidentiality agreements, camera and phone policies, health and safety policies, staff codes of conduct, and equal opportunities policies.
In consequence, many would-be parent volunteers are withdrawing their offers of help, leaving schools short of helpers to listen to children read or take them swimming. It also means that schools have to rely upon a small pool of vetted parents, who have the time and inclination to fill in forms and read lengthy policy documents.
This report argues that the situation for parent volunteers is the result of serious flaws in the vetting system, and the failure of reforms, which have merely confused and complicated the question of who should be vetted, and done nothing to restore trust in the majority of decent adults.
The growth of vetting
In June 2010, then home secretary Theresa May promised to ‘scale back’ criminal records checks to ‘common-sense proportions’. There was widespread recognition that vetting was creating mistrust, turning away volunteers, and absorbing the time and money of local community groups. With public criticisms raised by children’s authors such as Philip Pullman, the home secretary said that mass vetting treated everyone as ‘guilty until proven innocent’. It was time, she said, to begin ‘to trust each other again’.
The government drafted the Protection of Freedoms Bill, abolishing the vetting database and, it claimed, limiting vetting to only those in the ‘most sensitive’ positions. These changes were enacted in September 2012. In the wake of this, many assumed that a sensible balance had been struck and the problem of over-cautious vetting had now been solved. The government predicted that reforms would lead to ‘a reduction of some 50 per cent in the number of… certificates being issued, dropping from about 3.7 million a year to something like 1.7 million’.
This has not occurred. When criminal records checks (now known as DBS checks) failed to fall in the years after the Protection of Freedoms Act, officials said that this was because the system had not yet bedded in; and particularly that the new ‘update service’ (which allows people to subscribe to a database and avoid repeat checks) was not yet up and running.
Yet now, eight years after the initial statement, and six years after the new legislation, we are able to survey the effects of the policy. Far from decreasing, criminal records checks have continued to rise (1).
|Year (Apr-Mar)||Checks on Volunteers||Total Checks||Update service subscriptions
The number of checks is now higher than in 2012, the year the Protection of Freedoms Act was passed. Yet there has also been a substantial increase of subscriptions to the Update Service (and around 20% of these are volunteers). The Update Service (which allows people to be registered on a database, and for employers to check that a previous DBS check is still valid) has removed the need for repeat checks for over 1.2 million people. This suggests that the update service has partially masked a substantial entrance of new people into the criminal records check system; without the update service total checks would have surpassed 5 or even 6 million per year.
The problem lies with the reforms in the Protection of Freedoms Act. Rather than substantially limiting those who needed to be vetted, the reforms merely laid over another layer of regulation on top of the old, which made the system more confusing and did nothing to free groups such as volunteers.
For example, the question of who has to be vetted is included in a document which outlines what is known as ‘regulated activity’ (activity with children which falls under the vetting and barring system). This document lays out the conditions in which a person must be vetted: if they carry out care, supervision, teaching or instruction of children, either once a week, or four or more days in a 30-day period, or overnight. It also requires checking for anyone who gives physical help in relation to children’s washing, bathing or dressing.
Because this definition relates to the frequency of contact with children, or the kind of activity, it elides the distinction between very different roles. The category of ‘dressing’, for example, would include the person who looked after disabled children in a children’s home, as well as the mother who helped her daughter and her friends get dressed after swimming.
The regulations included a new exemption from vetting, which is called ‘supervised activity’. This exemption was aimed at reducing the vetting of volunteers, where they were under the supervision of a teacher or other child professional. And yet, rather than define supervision in the ordinary sense, as meaning a volunteer is working under the general supervision of a teacher, a guidance document defines supervision as that ‘reasonable in all the circumstances to ensure the protection of children’.
The document suggests that a head teacher should engage in detailed consideration of each volunteering role in order to discover whether a person should be vetted. In each case, ‘organisations should consider the following factors: ages of the children, including whether their ages differ widely; number of children that the individual is working with; whether or not other workers are helping to look after the children; the nature of the individual’s work (or, in a specified place such as a school, the individual’s opportunity for contact with children); how vulnerable the children are (the more they are, the more an organisation might opt for workers to be in regulated activity); how many workers would be supervised by each supervising worker.’
This means that it is not at all clear whether a parent volunteer is engaging in ‘regulated activity’ (which means they would have to be vetted) or ‘supervised activity’ (which means they would not), since this distinction could hang on the nature of the children, or the exact context of the work, which are things that could not possibly be known or predicted in the context of a busy school where the demands for volunteering would change from week to week.
In any case, the ‘supervised activity’ exemption is not available for any activity including ‘toileting’ or ‘dressing’, which would mean obligatory vetting for parent volunteers on pre-school trips (where children require help in the toilets) or swimming trips for younger primary age children (where children require help dressing).
The government also introduced a list of those who could be vetted, if the institution desired. This is known as the ‘eligibility’ for DBS checks, and included as ‘eligible’ all those who carried out an activity ‘infrequently’, which means any activity that is carried out ‘more than once’. Significantly, it also included as ‘eligible’ all those ‘roles that involve work which would have been regulated activity with children before changes were made to the definition in September 2012’. This means that parent volunteers are eligible for vetting, so long as they help out at an activity on more than one occasion.
Given the complicated nature of the definition of ‘supervised activity’, it is not surprising that schools would choose to continue to check all their volunteers as a matter of course.
The problem with the vetting system
Most people would agree that those who have professional responsibility for children should be regulated, and subject to checks, as is the case for people with professional responsibility in other areas. Previous child protection regulations were based on the professions, including social workers, teachers, childcare workers, and healthcare professionals.
The current system, by contrast, seeks to regulate people’s degree of relationship with children – for example, the number of times they have contact with children as part of their role – which brings a new range of adults within the state checking system.
This means that no significant difference is made between those who have professional responsibility for children, and a mother accompanying her child’s class on a walk to the local park.
The law does not recognise the informal sphere, and the great difference between informal activities and professionally regulated activities. These are distinctions that are clear in everyday life, and yet the legal system of regulation assumes an almost deliberate indifference, insisting instead on counting the number of exchanges between adults and children and regulating on this basis.
This new legal framework is based on the assumption that all adults pose a potential threat to all children; and specifically, that the frequency of an adult’s meeting or relating to children increases their potential risk to the child, and potential opportunity to abuse. Hence, what is being regulated is not a form of professional responsibility, but the social encounter between adults and children.
Parent volunteers in schools
The effect of this framework can be seen most obviously in examining the case of parent volunteers in schools. Some volunteers in schools are not parents – for example, there may be local retirees, or trainee teachers, who wish to gain experience or do something useful with their time. But many school activities – such as swimming, walking to the park, school trips, language exchanges, school events such as discos/fetes/Christmas fairs – would be of interest almost exclusively to the parents of children in that class. This is why schools target parents with calls for help in these activities.
Many school activities can only occur because of volunteers. A swimming pool trip requires an adult to every 5-7 children, which cannot be gained through the employment of professionals. A walking crocodile of children requires 5 or so adults for a class. Children need to practice their reading with adults one-on-one. What is required for these activities is something that most competent adults are able to provide.
The context for a parent volunteering for swimming is not that of a professional applying for a job: they will not be paid, they have no special skills, and they are only doing it because of their committed interest in these particular children (including their own) being able to go swimming. Through volunteers, a school draws on an informal web of relations that stretches from the institution into the surrounding community.
In most countries, this sphere would be entirely unregulated. Indeed, Australia has a comprehensive and in many ways over-cautious vetting system, yet it notably excludes parent volunteers, stating that it ‘considers that voluntary work done by parents to support their children should not be regulated by legislation’ and that ‘Attempting to capture and monitor these informal voluntary roles would discourage parents from offering to help and would not add to the protection of children’.
In France, parents wishing to accompany a school trip (including trips with overnight stays) merely add their name to a list or have a chat with the teacher. Parents helping out with swimming put their name on a list, and then must undergo a two-hour training course in how to teach young children to swim and ensure their safety in the water. Parents who perform governance roles in the school – for example, on the parents’ committee – are merely thanked and allowed to get on with it; there is no requirement that they undergo any checks or references.
The French system preserves the distinction between the formal and informal spheres; between the spheres of professional work and parent volunteers. While French teachers are subject to stringent regulation – including child protection regulation – parent volunteers are asked only to turn up as promised and ensure the children do not drown.
The vetting of parent volunteers
In the UK, the informal web surrounding school life, upon which certain school activities depend, is subject to a hostile and formal system of regulation, which runs counter to – and violates – the nature of those relations.
This notably includes requests for criminal records checks from parent volunteers. Our recent FOI requests reveal that the vetting of school volunteers reached 168,696 criminal records checks in the school year 2017-18 (2).
These checks were for the following volunteer roles:
Number of DBS checks
Terms in the ‘job applied for’ column
|School governor||30,172||parent governor, governor|
|Parent volunteer||17,213||parent volunteer, parent helper|
|Grand parent helper||41||grand parent volunteer, grand parent helper|
|Classroom helper||25,427||Classroom, class|
|Story teller||40||story teller|
||8998||host exchange, language exchange, student exchange, host family|
|Walking bus||54||walking bus|
|School disco||25||disco, school disco|
|School volunteer||92,531||helper in school, school helper, school volunteer, school|
These figures are are based on the text written in the ‘position applied for’ box on the DBS form. The figures are a minimum and approximate indication of the kinds of roles that school volunteers are being checked for. For example, a parent volunteer on a school trip could could simply have been described as a ‘school volunteer’, without specifying that they are a parent or helping out on a trip.
A survey of relevant message boards on Mumsnet suggests that:
1. Many schools are vetting volunteer parents as a matter of course, and that this vetting has increased (ie, schools that did not vet before have started doing so).
Ours get a DBS check for everyone. It means that once you’re a helper they can ask you to join a school trip, or hear a single child read, or whatever, without needing to check if you’re checked.
Our school now needs all parent helpers to be checked. This was always the case for regular help in the classroom, but has now been extended to one-off accompanying school trips and even just walking with a group of children with the teacher and other parents, eg if they go off site for any reason. In this latter situation there is no chance of being one-on-one with any child, and it is happening weekly at the moment.
I was a parent helper from when my daughter started reception and never had a check until almost the end of year 6 when I was listening to readers!! School paid for it and they said it was all a load of pc rubbish but I had to have it and also put a visitors badge on.
I had to have an enhanced dbs check to help at my dc (darling child’s) school. I’m on the PTA and only help at events, discos and the like. I don’t commit to regular hours as such but as and when I’m needed.
2. This includes parents even just entering a school to see their child:
I had to be DBS checked to go into DDs primary school to administer medication to her. I was only in contact with my own DD but as I had to go past the reception area, into the medical room that was in the main part of the school in a regular basis, I had to have the check.
3. Some parents are being asked to pay the cost of the check:
I personally feel this it a step too far… the school asks for parents to pay the cost of the check (apparently the LA charges them to process the application). It means that not many people can/will volunteer for things and the same people have to step up all the time. Including walking group of kids to a church or to a park.
4. Parents are being asked to undergo multiple and repeat checks:
We have to have our DBS re-applied for every three years in the school I work in.
My daughter helps voluntarily in her old school and if they have a gap of 3 months not visiting school, they have to re-apply.
Every helper is required to have a check whether you go in regularly or not. If you haven’t been in in 3 months, then you need another one before you can help again!
I had (a check) to listen to readers, and another to be on the playgroup committee.
A review of school websites also suggests that requests for DBS checks are a standard part of recruitment of volunteers. One Lewisham primary school says:
If we can find a position for you in the school you will also need to complete an online Disclosure and Barring Service (DBS) form – this has replaced the old CRB. An invite to complete the DBS can be sent to you from the school office. Once you have completed this, you will need to bring in the identification that you have selected. The DBS can take up to several weeks to be processed and we will be unable to offer you volunteer work until we receive confirmation of your status. The original DBS will be posted to your address and will need to be brought to the school office.
A Wiltshire school says:
Anyone wishing to become a volunteer, either for a one off event or on a more regular basis should read the information on the school website and complete the online volunteering application form. If successful, applicants will be invited in to school for an interview and tour. Before starting in school and to ensure the safety of our students at all times, all volunteers will be required to complete a DBS check. This will be arranged with the Office Manager. The check takes approximately two weeks to process. We are unable to have any volunteer in school unless they have a clear DBS and have shown their certificate in school. Induction packs will be issued to all volunteers and confirmation of a starting date will be confirmed in advance of the placement.
Here, we can see that the request for a DBS check is being required of all volunteers, regardless of whether they meet the required standards for ‘regulated activity’. This is not surprising, given the complicated nature of vetting regulations, and the underlying policy assumption that all contact between adults and children is a potential risk.
The result is that a parent walking the class crocodile to the sports field has a higher level of security clearance than many professional jobs, such as accountants, lawyers, the sellers of explosives, those applying for firearms licences, or people in national security positions. (These other professional positions are only subject to a basic check (which reveals convictions, cautions, reprimands or warnings), while the parent volunteer must undergo an enhanced DBS check, which additionally includes a search of local police files for any ‘soft intelligence’ that may be held on them.)
The habitual use of DBS checks for parent volunteers is also advised by safeguarding advisers and professional bodies, drawing on government guidance. For example, one safeguarding adviser says that his reading of the relevant guidance is that schools should check parents who are acting as host families on school language exchanges.
Other red tape
As well as vetting, volunteers are also asked to comply with a series of other bureaucratic requirements. Indeed, some schools ask volunteers to undergo the same checks and requirements as staff members, including providing a full professional history (including salary and grade), undergoing an interview, and then being assessed in their performance of the post. One school said that volunteers would be:
monitored by the leadership team under careful scrutiny of the Assistant Head Teacher. The policy will be supported by the confidentiality statement, the standards and expectations form and the volunteer/ work placement evaluation and feedback form.
The application forms can stretch to 9 pages long. Two mothers on Mumsnet complained:
The school my kids have just left made you basically fill in an application form the same level as a normal teacher application to go in to volunteer! Plus obviously DBS checks which are kind of par for the course.
The form was just absolutely unbelievable (and I’m used to teaching application forms) – then they go on about how they always welcome helpers in the classes – they bloody don’t!
One school asked volunteers to sign the school’s equal opportunities policy, saying that any disagreement with this policy would mean that they would not be accepted as a volunteer.
Where a prospective volunteer demonstrates hostility to, or a clear lack of support for equal opportunities, she/he will be deemed automatically unsuitable for a volunteer position. All volunteers are required to make a commitment to this policy. A copy can be given on request.
Another primary school‘s requirements for parent volunteers included:
This school is committed to safeguarding and promoting the welfare of children and expects all volunteers to share this committment. We will ask for:
• A DBS Check
• A Disqualification by Association Check
• Proof of identity
• Signed agreement that you will adhere to our Child Protection Policy, Health & Safety Policy, Behaviour Policy, Staff Code of Conduct, Whistleblowing Policy and Phones & Cameras Policy
You will receive a copy of it for your records.
A mother on Mumsnet says that she was asked to provide two safeguarding references to allow her to volunteer at the fete, Christmas fair and book sale. The form asked for two professional referees to answer the following questions:
How long have you known the candidate and in what capacity? Is there any significant record of misconduct or capability particularly that concerns the welfare or safety of children, then please give details here. If you have any concerns about the candidate’s suitability for working with children and young people then please give details here. Any further comments.
Once accepted, volunteers are often asked to abide by a detailed behavioural policy. One primary school says that parent volunteers should:
o Report to the Headteacher any incidents that suggest a pupil may be infatuated with you or taking an above normal interest in you
o Dress appropriately for your role
o Do not have e-mail or text contact with pupils
o Do not have contact with pupils via social networking sites such as Facebook or Twitter
o Avoid unnecessary physical contact with children
o Ensure you understand the rules concerning physical restraint
o Where physical contact is essential for educational or safety reasons, gain pupil’s permission for that contact wherever possible
o Allow children to change clothes with levels of respect and privacy appropriate to their age, gender, culture and circumstances
o Avoid working in one-to-one situations with children in spaces where you cannot be seen.
Again, this excessive red tape is encouraged by government guidance, and also by safeguarding advisers or organisations. One mother on Mumsnet says:
I’m doing a ‘safer recruiting’ course and volunteers should apply and be interviewed in the same way as a salaried staff member. Certainly, DBS is the absolute minimum that is to be expected.
The ‘recruitment’ system for volunteers is entirely at odds with the nature and ethos of volunteering; it subjects volunteering to a formality which would be expected for someone assuming a professional position. It also, in effect, makes volunteering into a contract – only where the obligations and sacrifices are all on the side of the volunteer, and there is neither remuneration nor rights in return.
The red tape to which volunteers are subjected has no discernible function: as the Mumsnet mother pointed out, her professional friends who would provide her ‘safeguarding references’ had no actual idea if she was a risk to children. Making volunteers sign a pile of policy documents doesn’t make them any safer, nor does it make them a good volunteer.
Nor are these procedures based on a judgement of the actual risk posed by parent volunteers, or the actual potential for child abuse on the occasion of a school trip or the crocodile to the park. It requires a mentality of a certain twisted kind – as well as a detachment from the realities of life – to see a mother accompanying her child’s class as a potential grooming and abuse threat.
The effect of vetting on volunteering
The result of this policy is that the first act of a parent volunteer (or ‘applicant’) is to fill in forms, hand over their passports, and wait for a police notice of their criminal ‘status’ – before they are cleared to go to the swimming class or be on the cake stall at the school fete. This fundamentally transforms the nature of the activity, and the nature of the relationship between school and volunteers. It creates a hostile, high-security atmosphere, rather like going through airport security or applying for a visa at an embassy, rather than performing an act of good will for your child and their friends.
The primary effect of vetting and other child protection procedures is that volunteers withdraw and decide not to help out. This particularly occurs when parents are busy or otherwise unable or unwilling to comply with the arduous requests. A few accounts on Mumsnet include:
I’ve been asked for the same when volunteering at DD1’s school this term – application form on the level that you’d be filling in for an actual teaching job, full work history and two references. I may actually not be able to volunteer there since the reason for doing so is to start to rebuild my work history and references after a career break – the heads I’ve worked for have retired or died (not my fault!) and I’ve left it with the volunteer coordinator to see what she can chase up in terms of factual references from supply agencies I’ve worked with in the past to tick her safeguarding boxes.
Considering I’ve got QTS, DBS checks out of the eyeballs and am there with time on my hands wanting to help – and even I’ve looked at the form mountain and got discouraged and considered not even bothering trying – and it’s not 100% I can get enough references together to satisfy them, they’re going to run very short of parent volunteers in a few years!
The primary school ds2 goes to now requires all parent helpers to have a check done if they have any contact with pupils (including helping on school trips etc). There is an admin fee charged by the umbrella body that processes the applications for the school, so the school will only undertake checks for regular helpers. This means ad-hoc helpers like myself who work full-time can no longer help on school trips – and the school keep repeating their requests for helpers!
Schools increasingly rely on a few ‘professional’ volunteers, who have the time and inclination to jump through the hoops (and who may even assume a certain pride and high-mindedness in so doing). Schools’ volunteers are restricted to an increasingly narrow pool, rather than drawing on the variety of parental help and goodwill available.
At our school it has the effect of meaning that they use the same three parents for every class trip. No-one else ever gets a look in as there is never “enough time to run the necessary checks”. I am not sure quite why I am so irked that I never get to spend one of my precious days off accompanying Year 5s round the local nature reserve or whatever. But it certainly means that schools rely on a small and highly used band of volunteers and are disinclined to open it up to others.
Conclusion – restoring trust
Vetting and other formal procedures should be concentrated on child professionals, who have exclusive and professional responsibility for children as part of their work. These same standards should not be applied to occasional volunteers, particularly not to parent volunteers.
We need to recognise the value of informal relations of trust – for example, that parents are known to the school, are part of a school community, and have a stake in the children’s wellbeing. Asking parents to undergo vetting and other procedures undermines these relations of trust, ultimately to the detriment of children’s welfare and safety. Britain should follow the Australian example and create a ‘parent volunteer exemption’ to criminal records checks, which recognises the value of informal networks around institutions.
We also need a return of common sense, and a recognition that the paedophilic orientation is extremely rare, perverted and criminal. As a society we cannot and should not hold the assumption that any adult who offers to help children has suspicious motives and should be regulated. Adults should be regulated according to their degree of professional responsibility, rather than according to the number of times a month they accompany the school crocodile.
Finally, the child protection system should focus on monitoring the small number of adults who are a known risk to children, primarily those who have convictions for child abuse. This would be a far more sensible use of resources than vetting the thousands of mums and dads who help out at their kids’ schools.
The vetting system is fatally flawed, and the Protection of Freedom Act reforms have done nothing to fix the problem that the government recognised six years ago. We need to go back to the drawing board – or else the children will have no one to help out at their Christmas Fair in years to come.
This report was supported by the Nigel Lord Vinson Charitable Trust.
(1) Data for 2002-2011 from FOI response, 17 April 2012; data for 2012-13 from FOI response, 26 February 2014; 2013-14 data from DBS FOI response, 12 May 2014; since 2014, data is available on the DBS performance statistics website.
(2) Data from FOI request to DBS, 28 November 2018